Haytham, Capt Grey and I already spoke with all the witnesses when we thought we were going to a 32. They are solid. Who do you want to do the next round of edits before we get the discovery request out? Christian P. Hur Captain, USMC Senior Defense Counsel Telephone: (619) 524-8713 Fax: (619) 524-6784 Address: Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140 This email may contain Attorney Work Product. Please delete if you received this message in error. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, December 01, 2010 5:26 To: Hur Capt Christian P; Rowe Maj Carlos O Cc: Grey Capt Nicholas R Subject: RE: Maj Rowe BOI Gentlemen, I have made some corrections, then turned on the track changes function. I would like this to be a joint effort. Lets remove the witnesses from this discovery request. I would like to have a chance to speak to all the witnesses before we request them. I don't have to personally do it but one of us must. I think the video idea is a very good one if it is still there. Remember, however, the government has no more power than we do. Maj Rowe should personally go to the establishment and see if they have the video. I think I remember that he has a good relationship with them. If there is a video, there is no better way to impeach then to surprise them with it after they testify. Maj Rowe. We need from you a solid list of 6 officers that can testify about you past performance and your character. They should be senior to you. -----Original Message----- From: Hur Capt Christian P [mailto:christian.hur@usmc.mil] Sent: Tuesday, November 30, 2010 6:09 PM To: Haytham Faraj; Rowe Maj Carlos O Cc: Grey Capt Nicholas R Subject: RE: Maj Rowe BOI As discussed, please review for editing. Also, don't forget that we have the assistance of Capt Grey, Esq. on this case too. Christian P. Hur Captain, USMC Senior Defense Counsel Telephone: (619) 524-8713 Fax: (619) 524-6784 Address: Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140 This email may contain Attorney Work Product. Please delete if you received this message in error. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Tuesday, November 30, 2010 11:53 To: Rowe Maj Carlos O; Hur Capt Christian P Subject: RE: Maj Rowe BOI Reviewed it. Thanks. Go ahead sign and return. I will draft a request to continue the Board until February because I will not be available before then. Chris, please put together a witness request to the CA. We need a 6-8 good character witnesses. We should also request percipient witnesses that can challenge the events alleged. Carlos, I need you to get together every fitness report, letter of appreciation, certificate, award and anything else that is positive from your career. I want you to start working on a statement for the board. The one you created for the General is a good starting point. I also want to know if you know of anything negative in your accusers personal files. I DO NOT WANT YOU to obtain anything or send out anyone to get anything. I simply want to know if there's anything negative there. -----Original Message----- From: Rowe Maj Carlos O [mailto:carlos.rowe@usmc.mil] Sent: Tuesday, November 30, 2010 2:31 PM To: haytham@puckettfaraj.com; Hur Capt Christian P Subject: FW: Maj Rowe BOI FYI -----Original Message----- From: Grogan 1stLt Stephen J [mailto:Stephen.Grogan@marines.usmc.mil] Sent: Tuesday, November 30, 2010 13:18 To: Rowe Maj Carlos O Subject: FW: Maj Rowe BOI Sir, You will find the page requiring your signature on Enclosure (2) of the document. Please date the document as well. Thank you for your assistance. I will CC you on my submission to SJA. Very Respectfully, First Lieutenant Stephen J. Grogan Adjutant Ninth Marine Corps District 3805 E. 155th St., Bldg 710 Kansas City, MO 64147-1309 Phone: (816) 843-3879 E-mail: stephen.grogan@marines.usmc.mil Web: http://www.marines.mil/unit/mcrc/9mcd -----Original Message----- From: Keske Maj Zenon W [mailto:zenon.keske@usmc.mil] Sent: Tuesday, November 30, 2010 1:56 PM To: Grogan 1stLt Stephen J Cc: Bonnot Col Matthew J; Sullivan LtCol Sean Subject: Maj Rowe BOI 1stLt Grogan, Good morning. The CG, MCDC, has directed Maj Rowe to show cause for retention in the Marine Corps. Attached is the notification letter from the Depot Commander. Included as enclosures are Maj Rowe's rights at BOI and an acknowledgment form for his signature. Please give the attachment to Maj Rowe and scan and email me a copy of the signed acknowledgement and mail the original. We'll coordinate the date and time of the board with his defense counsel. If there are any questions, let me know. r/s Maj Keske Maj Zenon Keske Deputy Staff Judge Advocate MCRD, San Diego DSN: 524-4103 Comm: (619) 524-4103 zenon.keske@usmc.mil zenonkeske@yahoo.com WARNING: ATTORNEY WORK PRODUCT Information contained in this correspondence may be ATTORNEY WORK PRODUCT; this material is confidential and protected by applicable law, and is authorized for viewing by its intended recipients only. If you have received this message in error, reply to the sender immediately, and destroy any copies and attachments, electronic or print, which you have made of this message. PRIVACY ACT WARNING: This message may also contain information protected by the Privacy Act of 1974 and other law or regulation pertaining to the safeguarding of Personally-Identifiable Information (PII). Improper disclosure of the contents of this email may give rise to civil and/or criminal penalties.
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